Steven Alan Kraselsky, personel representative of the estate of Marcia Kraselsky v. David Calderwood, M.D., and Huntsville Clinic, Inc., 166 So. 3d 115

Marcia Kraselsky, age 80, was hospitalized in July 2010 for complications including bilateral pulmonary emboli, rib fractures, GI bleeding, and congestive heart failure after an earlier cardiopulmonary arrest.
Her primary-care physician, Dr. David Calderwood, ordered IV Demerol (meperidine) on July 19 despite Marcia's recorded history of multiple drug "allergies," including to Demerol; nursing staff verified the allergy but administered the drug after Calderwood confirmed the order.
Marcia's respiratory status worsened after Demerol administration; she was moved to the ICU, experienced cardiopulmonary arrest, was resuscitated, and died on July 22, 2010.
Steven Alan Kraselsky (personal representative) sued Calderwood and Huntsville Clinic for medical malpractice, alleging ordering Demerol despite known allergy caused the decline and death; the hospital was voluntarily dismissed.
Defendants moved for summary judgment arguing plaintiff lacked substantial evidence of breach and, crucially, proximate causation; the trial court granted summary judgment for defendants, and plaintiff appealed.
The Alabama Supreme Court affirmed, holding plaintiff failed to produce substantial evidence that the Demerol administration probably (not merely possibly) caused the decline and death.

Issue	Plaintiff's Argument	Defendant's Argument	Held
Whether proximately caused injury/death by Demerol (causation)	Dr. Siddiqui's deposition shows Demerol could have been the "tipping point" and thus proximately caused deterioration and death.	No substantial evidence establishes Demerol probably caused the decline; comorbidities (embolus burden, CHF, sepsis, GI bleeding) more plausibly caused death.	Held for defendants: plaintiff failed to show by expert evidence that Demerol probably caused the death — only possibility was shown.
Whether there was a breach of standard of care by ordering Demerol despite recorded allergy	Plaintiff asserted ordering Demerol breached the standard of care given recorded allergy and that breach caused harm.	Defendants disputed breach and noted prior tolerance and physicians' assessment that reported symptoms were side effects not true allergy; even assuming breach, causation lacking.	Court assumed arguendo a breach but declined to decide it; affirmed summary judgment based on lack of proximate-causation evidence.

University of Alabama Health Servs. Found. v. Bush, 638 So. 2d 794 (Ala. 1994) (plaintiff must prove negligence probably caused injury in malpractice cases)
Bradford v. McGee, 534 So. 2d 1076 (Ala. 1988) (mere possibility of causation is insufficient)
Giles v. Brookwood Health Servs., Inc., 5 So. 3d 533 (Ala. 2008) (expert testimony must be viewed as a whole; isolated excerpts cannot defeat summary judgment)
Hines v. Armbrester, 477 So. 2d 302 (Ala. 1985) (court must evaluate expert testimony in context)
Malone v. Daugherty, 453 So. 2d 721 (Ala. 1984) (same principle on viewing expert testimony as a whole)
Dow v. Alabama Democratic Party, 897 So. 2d 1035 (Ala. 2004) (standard of review for summary judgment)